Firstly, may I thank the Group for inviting me, as Chair of the Horseracing Bettors Forum, to address them on the question of “are bookmakers unfairly closing customer accounts?”

In the correspondence leading up to this event, one of my fellow speakers was described as “neutral”, but HBF would like to emphasise that it does not wish to be seen as merely speaking for one side in this debate: it seeks co-operation and to work towards a fair resolution of any problems that there may be.

I will briefly explain what HBF is and what its aims are.

HBF was created in 2015 with the assistance of the British Horseracing Authority to understand and represent the hopes and concerns of those who bet upon, or who might bet upon, horseracing in Britain.

It has between 7 and 9 members, including me as Chair, and meets quarterly as well as corresponding extensively between those meetings. Its membership has been derived from public calls for interest, the most recent of which was last summer.

HBF is unfunded other than having minor expenses defrayed by the BHA. The Forum sees holding the BHA to account as one of its primary objectives, and the BHA has been supportive, including in this regard.

Previously, the betting public was – at least occasionally – seen as a key customer group in British racing but had no voice or means for raising concerns.

HBF has established a website, e-mail address and Twitter account, all with a view to engaging with the public it seeks to represent. Its members have also met with the public at racecourses and at racing clubs.

In the two and a half years since HBF’s inception, the subject most frequently raised with HBF has been that of the closure and restriction of betting accounts.

Contrary to some opinion, that has not just been from high-rolling gamblers but from small-staking ones as well, and not just from winners but sometimes from losers, too.

Account “closure” is self-explanatory, but it has become apparent that some “restrictions” are so draconian that they serve much the same end, while – the cynic might suggest – leaving the door ajar to a spin or two on the virtual roulette table.

There are countless anecdotes about bets being restricted to derisory sums, and bookmakers have confirmed that some customers have been “factored” to a minute fraction of the bets they request.

HBF understands the desire for sensible risk management, but it believes that restrictions and closures are being implemented too readily, and that the consequences of this for horseracing and for betting on the sport are harmful and are not being taken seriously enough.

HBF ran a survey of the betting public in 2016, to which there were nearly 1000 respondents, with 59% of those who stated that they had had accounts closed or restricted claiming to have suffered a reduction in interest in the wider sport as a consequence.

By extrapolating from the figures reported, in conjunction with information provided separately but confidentially to HBF by a leading bookmaker, HBF estimated that as many as 20,000 accounts had been closed in the previous six months.

The immediate harm to an individual bookmaker of wrongly restricting or closing the account of a given punter may be small, but the potential harm to the sport is much greater, as it could lose a lifelong fan.

Ultimately, if that happens often enough – and the evidence is that it is happening more than occasionally – then it threatens to poison the well for all concerned.

Risk management should not be taken to equal risk elimination. Betting on horseracing by its nature involves risk – whichever side of the counter you are on – and that is a significant part of its appeal compared to some alternatives.

It is crucial to betting on the sport, and to the sport itself, that it remains aspirational. That it should be possible, in theory, to turn a profit, or at least to lose less, by applying enough skill and discipline.

By acquiring that skill and knowledge, an individual may well become an advocate for, and contributor to, the sport of horseracing itself.

The modern betting landscape seems to have lent itself to a safety-first attitude to risk management. Where once it might have taken many bets to establish that a punter was “hot”, individuals are having accounts closed or restricted sometimes as a result of just a few bets.

Those bets do not have to have been successful, just to resemble the fingerprint of someone who may, possibly, be successful in the future. As an example, those who bet on horses who subsequently shorten in price seem to be prime targets for restriction.

The Chair will be familiar with the details provided by one of his constituents, who is present here, of that constituent’s severely restricted accounts. Those accounts have been for average bets of just £15 and have effectively done no more than break even over a number of years.

The individual’s apparent “crime”? It was that, in amongst those bets, he backed enough horses at odds longer than Starting Price to have aroused suspicion.

Incidentally, I would like at this point to acknowledge, and pay tribute to, the fine work done by the group Justice For Punters, in this specific instance and in the area of account restrictions and closures more widely.

In our survey, 20% of respondents claimed to have been closed (not just restricted) after less than 10 bets, 37% after 20 or fewer.

As a result, it seems likely that there are thousands of “false positives”: of people closed or restricted by accident.

This haste in applying closures and restrictions has led to some punters becoming more “inventive” at trying to get a bet on. HBF wishes to make it clear that it does not condone the adoption of aliases, of impersonation, and the like.

But this ensures a vicious circle, whereby bookmakers become increasingly suspicious of betting behaviour, and a small section of punters become more resourceful in trying to get round the restrictions imposed. The whole situation escalates.

The Horseracing Bettors Forum would like to be a part of breaking this vicious circle and of creating a better environment for the majority of the betting public. At present, too many “innocents” are being caught up in restrictions and closures aimed at discouraging the very few.

One part of the solution might be a minimum-bet commitment from bookmakers.

It is what HBF has called for in its Betting Charter – along with advanced protection of punters’ funds, greater clarity on Terms & Conditions and other items – and we have discussed the matter with a small number of co-operative bookmakers in Britain.

On a recent visit to Australia, I met with a leading corporate bookmaker and discussed minimum-bet commitments with them.

A number of States in Australia have now adopted this as a condition of licence, and those I spoke to in Victoria were notably enthusiastic about the initiative.

They believe it has led to them being able to set more informed markets and to serve a wider section of the betting public at little increase in initial cost.

They claim that subterfuge and cloak-and-dagger activity has virtually disappeared as all but the largest-staking punters have been able to get a reasonable bet on.

There are some differences between the betting landscape in Britain and Australia, but far more similarities. Several of the biggest corporate bookmakers in Australia are in fact owned by British betting companies.

Another, related, option is to offer punters “no frills” accounts, without promotions and/or best-odds guaranteed, but with this commitment to a minimum bet. This should be an option, rather than an obligation: different punters will want different things.

HBF would also like to see better communication between bookmakers and customers prior to closure or restriction.

At present, the first time a punter is likely to know that his or her business is no longer wanted is when he or she gets a generic e-mail advising that closure or restriction is a “trading decision” and not open to discussion.

We believe a customer should be told which behaviours may lead to this outcome – such as a suspicion of arbing, or line-tracking, or of holding multiple accounts under different identities – before closure becomes final and irreversible, so that those behaviours may be explained or changed.

This seminar’s title is “are bookmakers unfairly closing customer accounts?” In summary, HBF would argue that closures and restrictions are indeed unfair in some instances.

As much to the point, however, is that they are proving to be counter-productive, for the sport of horseracing, for those who would bet on it, and – we would argue – even for the bookmakers themselves in the longer run.

All concerned need to enter into dialogue about this matter – such as through the soon-to-be-formed Racing and Betting Liaison Group at the BHA – and HBF very much appreciates this Parliamentary Group’s willingness to set the ball rolling with this seminar.